Europe is facing an uncertain and radical transition of our energy supplies and industrial base, fostered by a combination of geopolitical threats and shocks, climate change, and economic necessity. Under these circumstances, it is necessary that the EU utilises the expertise and industrial potential we have at hand to reach aforementioned objectives. As one of the largest energy consumers, strengthening the European heating sector will be essential to achieving climate and economic objectives.
Energy labelling is a tool that has delivered considerable energy efficiency savings across Europe by assisting consumers in selecting the most environmentally friendly products. It has also proven to be an effective tool to push the industry to produce more efficient products.
In this context, the undersigned associations are alarmed by the proposal from the European Commission to merge the energy labelling requirements for air-to-air heat pumps and air conditioners (AAHPs) on the one hand and local space heaters (LSH) on the other. This proposal would result in confining LSH to the lowest part of the energy labelling scale, with no possibility of differentiating the best or worst performers.
We - the undersigned associations, representing the European heating appliance manufacturing sectors and their supply chain, ardently support the EU initiatives to achieve its climate objectives while strengthening Europe’s industrial base - believe that this would have negative consequences, for the reasons described below:
1) AAHPs and LSH are not competing with each other
First, because these products are not competing, and should therefore not be compared with each other on a single energy labelling scale. AAHPs have reduced energy use when heating large spaces in milder climates. At the same time and contrary to AAHPs, LSH (such as underfloor heating, an electric fixed emitter, a pellet or biomass heater, or an infrared panel) provide instant heat that is indispensable for health and comfort in colder climates and in smaller spaces. Often, AAHPs and LSH work together to achieve the desired results in buildings. This can be compared to the symbiosis in other sectors: for example, laptops and mobile phones are complementary as ICT devices used for communication, with different applications and purposes.
2) Comparing incomparable products will negatively impact consumer choice
It should also be noted that LSH and AAHP are often not interchangeable, for technical and economic reasons. Placing them under a joint energy labelling scale would confuse consumers, as they may be misguided into believing that different heating technologies are interchangeable. In reality, both product groups differ in their functionalities (i.e. purposes), have highly different heating capacity ranges, impose different installation requirements, have different distribution and installation outlets, and bear different costs. In addition, LSH are also powered by a wide range of energy sources: from fossil fuels to renewables (biomass, electricity, hydrogen). It would be nonsensical to place them against each other and push consumers towards an ‘either …, or…’ decision.
The current energy labelling classes for different heating categories already allow customers to choose the most energy efficient product within the product groups that are most suitable for their specific purposes. We support this system, as it has led to a bottom-up pull by consumers demanding more efficient heating products. Changing this will limit the incentive to invest in improving the energy performance of heating. Moreover, as the test procedures for the different product groups have not been harmonised, the results, and therefore also the energy efficiency, of the various product groups cannot be compared. In order to achieve comparability, the European standards prescribing testing procedures should first be harmonised across the product groups.
3) The Commission proposal penalises electricity as an energy source
In addition, the Commission’s proposal includes the Primary Energy Factor (PEF) in its energy efficiency calculation, which means that the efficiency score of electric appliances is artificially lowered by applying a PEF. This is odd, because LSH are increasingly powered by renewable energy, more and more directly with photovoltaic power generation on the roof of or close to the building. Moreover, electrification through renewable power generation is a generally supported method to lower our reliance on fossil fuel imports. Since LSH have a long lifetime, the PEF gives false information. On top of that, smart electric LSH may be very useful for grid stabilisation and up-take of renewable energy, as recognised by the Regulation (EU) No 2071/1369. If this had been done for all electricity-powered products, electric vehicles might have been classified as less efficient than the most polluting diesels. As such, we propose to remove the PEF from the energy efficiency calculation for heating ad to base energy efficiency on final energy.
4) Affordability of heating in times of an energy crisis and beyond
Moreover, the current energy crisis also created an ‘affordable energy’ crisis, driving more and more Europeans into energy poverty. With European winters still being relatively harsh, it is essential for human health and wellbeing to have appropriate, affordable heating. LSH can often easily and quickly be upgraded to achieve higher performance; for example, LSH can be equipped with smart controls to optimise energy use and interact with a smart grid through demand-side flexibility. This makes LSH suitable for affordable and easy solutions to help millions of people, especially in dwellings where it is cost-ineffective and/or technically infeasible to install AAHPs, such as most collective housing blocks.
In line with that, the proposal for a merged energy label penalises households that are living in buildings that, due to historical reasons (and cost-effectiveness and rentability reasons), cannot install an AAHP. Upgrading and replacing LSH then requires an energy labelling system that distinguishes the efficient from the inefficient appliances, which means that LSH need to be able to move between various energy labelling classes. By lumping LSH in one or two default energy labelling classes (as proposed by the Commission), consumers and installers will not be supported anymore by the energy label to choose the most efficient device and manufacturers will not be incentivized to produce more efficient devices.
Therefore, we believe that LSH should not be subject to a combined energy labelling scale with AAHPs.
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